American Banking Hegemony, A View From Europe

More than eight years after the beginning of the financial crisis, U.S. banking groups are dominating the financial world more than ever. This leadership has technical, political and legal grounds. But it also relies on one quintessentially American quali

PARIS — On this side of the Atlantic, the following statement will make most people groan: Despite the financial meltdown that began in 2007 in the United States, American banking groups dominate the financial world more than ever.

As evidence of this, the upper ranks of the global mergers and acquisitions are all occupied by U.S. investment banks. Wall Street banks have also just reaped record profits, even though they were admittedly generated by cost-cutting plans rather than new business. The tools of American leadership are simultaneously technical, political and legal. But its surprising durability can also be explained by one essential quality: rock-solid pragmatism.

This characteristic was rapidly apparent in the way the crisis was handled: In 2007-2008, many banks closed down. Without mercy, the sector immediately made the most of the situation to consolidate. Unlike what happened in Europe, the disaster led to the emergence of new financial empires in the United States. As early as 2008, Bank of America leaped to the rescue of Merrill Lynch, and JPMorgan took over Bear Stearns for a very low price. The growth of these giants wasn't hindered by post-crisis measures passed by the American authorities, and this, despite the 2010 Dodd-Frank law, which, on paper, aimed at toughening bank solvency rules and reinforcing the powers of regulators.

U.S. banks weren't particularly weakened by the avalanche of fines imposed by regulators. To this day, Wall Street has paid more than $180 billion for its responsibility in the financial crisis. But, as huge as they may be, these penalties are four times less than the profits it has accumulated since 2007 ($700 billion).

Most importantly, U.S. authorities saved the corner stone of their banking system: the two agencies Freddie Mac and Fannie Mae. On the verge of ruin at the moment of the crisis, these two institutions now own or guarantee half the mortgage loans in the United States. Loans that they buy off commercial banks are resold to investors in securitized forms. This system, which was at the rotten heart of the subprime mortgage crisis, was somehow maintained and now stabilizes real estate financing in the U.S.

But it's not the only advantage. By helping banks control the size of their balance sheets, Fannie and Freddie also give American lenders a step ahead on the global regulation stage. Since the crisis, various ratios with abstruse names — solvency ratio, leverage ratio or the new TLAC (Total Loss Absorbing Capacity) — have indeed forced banks to cut costs or massively recapitalize. In this context, the large-scale securitization carried out by the twin agencies is an efficient way to control balance sheets.

This American domination can be felt in the very conception of all these rules. When a new norm enters the public sphere, the discussions usually follow the same sequence: First, the text seems easier to implement in the U.S., with European countries only managing to consider the project afterwards. Paradoxically, this situation doesn't necessarily result from deliberate or fervent lobbying. Some just see in this the natural weight of the world's No. 1 economy.

EU v. UK

The dollar is, of course, the other major attribute of the power: American banks have privileged access to it, and all the international groups who wish to work with the currency have no other choice than to yield to the rules decreed on the other side of the Atlantic. It is indeed the use of the dollar that made it possible, from an American point of view, to accuse BNP Paribas of having violated economic embargoes, which led, in June 2014, to an exceptional $9 billion fine.

Faced with this steamroller, Europe should stand together. But it's still very fragmented. On the Old Continent, the banking playing field — even though cross-border rapprochements have taken place — still has largely national dimensions. Instead of growing like their American rivals, they are undergoing a weight-loss program, focusing on certain jobs and geographic areas. After RBS and Barclays, Deutsche Bank launched a major reorganization.

On the institutional level, the recent banking union project, a set of rules and institutions meant to create a real single Europe of banks, is a huge leap forward. But the Eurozone — managed by the ECB and a single banking supervisor — and the powerful City in London don't necessarily share the same interests.

The European banking regulations project that is currently discussed provides another example. Originally, this text, which was aimed at separating retail banking market activities concerned 30 major banks within the European Union. The United Kingdom demanded to be excluded from it, claiming that similar regulations are already applied to its own banking groups. Since then, negotiations have been in full swing, as the limits of the text grow tighter and tighter, to the point that it seems that the major French groups may now be almost the only ones concerned. It is just these kinds of clashes that also wind up benefiting American banks.